In the 1916 case of Minneapolis & St. Louis Railroad Company v. Winters, the U.S Supreme Court ruled in favor of the railroad company and reversed a judgment from a lower court that had awarded damages to Winters for injuries sustained while working as an employee for the railroad company. The primary issue was whether or not negligence on part of another employee could be attributed to his employer under federal law (the Federal Employers' Liability Act). The Supreme Court held that such attribution is only possible if it can be proven that said negligent act was committed within scope of employment duties by fellow servant, which wasn't established in this case. Therefore, no liability could be imposed upon Minneapolis & St. Louis Railroad Company based on its other employees’ actions.

In the dissenting opinion for Minneapolis & St. Louis Railroad Company v. Winters, Justice Holmes disagreed with the majority's decision to uphold a state law that allowed damages to be awarded without proof of negligence in cases where livestock was killed by trains. He argued that this ruling violated the Fourteenth Amendment's due process clause because it unfairly penalized railroad companies even when they were not at fault. In his view, such laws should only apply if there is evidence of negligence or misconduct on part of the railroads and not as an absolute liability regardless of circumstances surrounding each incident.